Allowing the petition, the High Court held that the assessee had addressed a letter dated October 8, 2014, to the officer in the course of assessment proceedings, pointing out in clear terms that certain shares were sold. The Department already had the information on that count. If the officer was not satisfied with the explanation furnished by the assessee at that stage, he could have exercised powers to make an addition, but he did not choose to do anything on such count. Therefore, the action of the Assessing Officer was in the nature of a change of opinion only. The notice of reassessment was not valid. The Revenue filed an SLP before the Supreme Court  there was delay of 429 days.  The reasons assigned for explaining the delay are neither satisfactory nor sufficient. SLP of Revenue is dismissed.   (AY. 2012-13)